South Africa & Ghana: The Continent’s Regulatory Laboratories

Across Africa, regulation is not evolving uniformly. While some jurisdictions are still consolidating foundational frameworks, others are actively testing new supervisory approaches, governance models and enforcement mechanisms. In this context, South Africa and Ghana stand out as two of the continent’s most important regulatory laboratories—countries where reforms are not only being adopted, but actively stress-tested in real market conditions.

Understanding what is happening in these two markets offers valuable insight into where African regulation is heading next, and what risk leaders across the continent should prepare for.

Why “regulatory laboratories”?

The idea of a regulatory laboratory goes beyond having modern laws or updated regulations. It refers to jurisdictions where regulators are experimenting with how supervision is applied: how accountability is enforced, how evidence is evaluated, and how risk management is expected to operate in practice.

South Africa and Ghana fit this profile for different but complementary reasons. South Africa functions as a systemically important financial market with strong global integration. Ghana, meanwhile, has positioned regulation as a tool for reform, stability and confidence-building after periods of financial sector stress. Together, they are shaping regulatory expectations that are likely to influence other African jurisdictions.

South Africa: Accountability, resilience and governance under scrutiny

South Africa’s regulatory environment is among the most advanced on the continent. Its recent removal from the FATF grey list in October 2025 marked a significant milestone in strengthening financial integrity and supervisory effectiveness.

This exit followed a multi-year reform process addressing deficiencies in beneficial ownership transparency, supervisory enforcement and inter-agency coordination. The South African government publicly confirmed the exit and its commitment to sustaining reforms through a statement from the National Treasury.

Beyond AML/CFT, South Africa is acting as a testing ground in three key regulatory areas.

First, board-level accountability has moved to the centre of supervisory attention. Regulators increasingly expect Boards of Directors to demonstrate active oversight of cyber risk, operational resilience and conduct risk. While board members are not expected to manage technical systems, they are held accountable for governance failures, insufficient oversight and weak decision-making structures.

Second, operational resilience has become a formal supervisory priority. Financial institutions are expected to identify critical services, map dependencies, test disruption scenarios and demonstrate recovery capabilities. This mirrors approaches seen in jurisdictions like the UK and EU, placing South Africa at the forefront of resilience-based supervision in Africa.

Third, beneficial ownership transparency has shifted from policy ambition to operational requirement. Amendments to the Companies Act and the Financial Intelligence Centre Act strengthened ownership disclosure mechanisms, supported by expanded supervisory powers of the Financial Intelligence Centre (FIC).

Through these reforms, South Africa is effectively testing how far regulators can push governance, accountability and resilience expectations before they become continental norms.

Ghana: Reform-driven supervision and financial integrity

Ghana’s role as a regulatory laboratory is shaped by a different starting point. Following a period of financial sector instability, Ghana embarked on an ambitious reform agenda aimed at restoring confidence, strengthening supervision and improving financial integrity.

At the centre of this effort is the Bank of Ghana, which has reinforced its approach to risk-based supervision across banks, payment service providers and fintechs. Supervisory expectations increasingly focus on governance quality, internal controls and the ability of institutions to manage operational and financial risks in a structured way.

Ghana has also strengthened its AML/CFT framework, enhancing the role of the Financial Intelligence Centre and improving coordination with domestic and regional authorities. Increased emphasis has been placed on customer due diligence, transaction monitoring and beneficial ownership transparency, particularly in higher-risk sectors.

Another area where Ghana acts as a regulatory testing ground is digital financial services. As mobile money and fintech adoption expand, regulators are continuously refining licensing requirements, outsourcing rules, third-party risk management and consumer protection standards. This adaptive approach allows regulation to evolve alongside innovation, rather than lag behind it.

Policy direction and reform priorities are also reflected in publications from Ghana’s Ministry of Finance, which frame regulation as a tool to support stability and sustainable growth.

Ghana’s experience demonstrates how regulation can be used not only to control risk, but to actively rebuild trust and guide financial sector development.

Two laboratories, one regulatory direction

Despite differences in market size and maturity, South Africa and Ghana show a clear convergence in regulatory philosophy. Both are moving away from checklist-based compliance toward evidence-driven supervision. Both are raising expectations around governance, accountability and data quality. And both are signalling that risk management is no longer a back-office function—it is a core organisational capability.

What differs is emphasis. South Africa is testing accountability and resilience in complex, systemically important institutions. Ghana is refining supervision in fast-growing, digitally enabled markets. Together, they offer a preview of Africa’s regulatory future.

What risk leaders should take from these regulatory laboratories

For organisations across Africa, the lessons are increasingly clear. Boards will be expected to understand risk, not merely receive reports.

Manual and fragmented risk processes will struggle under evidence-based supervision.

Financial integrity, cyber resilience and operational continuity will be supervised as interconnected risks, not isolated domains.

The regulatory laboratories of today often become the regulatory baseline of tomorrow.

South Africa and Ghana are not exceptions—they are indicators. They show how African regulators are experimenting, learning and refining supervisory approaches in response to both global standards and local realities.

For organisations willing to learn from these laboratories, there is an opportunity to prepare early, strengthen risk culture and build systems that scale with regulatory complexity. For those that wait, adaptation may come faster—and with far less room for error.

Africa’s regulatory future is being tested today. The question is whether organisations are paying attention.

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